S. VSeries Editor’s Preface

The LL.M. program in International Tax Law at WU (Vienna University of Economics and Business) is available as either a 1-year full-time or a 2-year part-time program. Students not only attend a vast number of courses for which they prepare papers and case studies as well as sit numerous examinations but also write their master’s theses. These theses are a prerequisite for the academic degree Master of Laws (LL.M.).

The program follows a scheme under which the master’s theses of one particular program all examine various aspects of the same general topic. Previous general topics have included:

• Electronic Commerce and Taxation (1999/2000 full-time program)

• Partnerships in International Tax Law (2000/2001 full-time program)

• Transfer Pricing (1999/2001 part-time program)

• Exemption and Credit Methods in Tax Treaties (2001/2002 full-time program)

• Permanent Establishments in International Tax Law (2002/2003 full-time program)

• Non-Discrimination Provisions in Tax Treaties (2001/2003 part-time program)

• Triangular Cases (2003/2004 full-time program)

• Tax Treaty Policy and Development (2004/2005 full-time program)

• Source versus Residence in International Tax Law (2003/2005 part-time program)

• The Relevance of WTO Law for Tax Matters (2005/2006 full-time program)

• Conflicts of Qualification in Tax Treaty Law (2006/2007 full-time program)

• Taxation of Artistes and Sportsmen in International Tax Law (2005/2007 part-time program)

• Fundamental Issues and Practical Problems in Tax Treaty Interpretation (2007/2008 full-time program)

• Dual Residence in Tax Treaty Law and EC Law (2008/2009 full-time program)

• Taxation of Employment Income in International Tax Law (2007/2009 part-time program)

• The EU’s External Dimension in Direct Tax Matters (2009/2010 full-time program)

• History of Tax Treaties (2010/2011 full-time program)

• Permanent Establishments in International and EU Tax Law (2009/2011 part-time program)

• International Group Financing and Taxes (2011/2012 full-time program)

• Limits to Tax Planning (2011/2013 part-time program)

• Exchange of Information for Tax Purposes (2012/2013 full-time program)

• Tax Policy Challenges in the 21st Century (2013/2014 full-time program)

• Global Trends in VAT/GST (2013/2015 part-time program)

• S. VINon-Discrimination in European and Tax Treaty Law: Open Issues and Recent Challenges (2014/2015 full-time program)

• Preventing Treaty Abuse (2015/2016 full-time program)

• Limiting Base Erosion (2015/2017 part-time program)

• Taxation in a Global Digital Economy (2016/2017 full-time program)

• Arbitration in Tax Treaty Law (2017/2018 full-time program)

• Transfer Pricing and Value Creation (2017/2019 part-time program)

• Special Features of the UN Model Convention (2018/2019 full-time program)

• Hybrid Entities in Tax Treaty Law (2019/2020 full-time program)

• Concept and Implementation of CFC Legislation (2019/2021 part-time program)

• Access to Treaty Benefits (2020/2021 full-time program)

• Justice, Equality, and Tax Law (2021/2022 full-time program)

• Multilateral Cooperation in Tax Law (2021/2023 part-time program)

• Tax and Technology (2022/2023 full-time program).

• The Global Minimum Tax - Selected Issues on Pillar Two (2023/2024 full-time program)

• Environmental Taxation (2024/2025 full-time program)

The respective master’s theses were published in edited volumes.

The general topic for the 2023/2025 part-time program was Anti Abuse Rules in International Tax Law and their Interactions. Susi Hjorth Baerentzen introduced the students to the subject matter at the beginning of the program. Christian Knotzer and Ivan Lazarov held workshops in which the structure of the papers and the preliminary results were critically analysed. It was with great commitment that they supported the students who were preparing their theses. Their numerous suggestions helped to improve the quality of those theses and, as a consequence, the quality of the present volume. In my function as both the scientific director of the LL.M. program and the editor of this series, I would like to not only thank those two colleagues for their excellent engagement and efforts but to also express my gratitude to them.

Finally, I am also grateful to the students themselves. They pursued the program with great enthusiasm. This LL.M. program not only gave them the opportunity to interact with academics and scientifically qualified interns from all over the world and to acquire a wealth of knowledge, but they also learned how to effectively address and solve complex issues using a structured approach. The master’s theses that are now available bear witness to this. I hope that the results of these papers will both influence scientific discussion and be of use to tax practitioners.

Michael Lang